Our bank ended 2003 over the $250 million mark for the first time. Our next CRA exam is in 2005, at which time we will still be examined as a small bank. My question, however, relates to small business and community development loans -- even though our next exam will use the small bank criteria, given the fact that we are over $250 million, are we required to report the business and community development loans that we make?

The definition of a small institution is any that had total assets less than $250 million in either of the prior two calendar years. So, you would still be considered a small institution in 2004. I think you would start collecting data in 2005 to be reported March 1st, 2006.

You're in a very good position now though (if you believe you'll be staying over $250MM) to get a program in place for reporting data. If you believe that you'll be reporting as a large bank in the next year or two, you might consider starting now (putting the systems in place to gather the data) so you can test your ability to report accurately when the magic date comes into play. I know you have a bit of time, but a year flows pretty fast around here. We've been large for many years, but it's still taken me three years to figure out what bugs we had in our system. Focus on this when we were small would have been a much better option and fixing the issues now.

Another local bank did just what I'm suggesting, beginning the reporting internally as well as testing when they hit $250MM. When they finally had to go into reporting mode they were in fabulous shape to do so.